The Nuclear Regulatory Commission is considering a draft rule that would eliminate the ALARA principle: the longstanding standard requiring radiation exposure be kept "As Low As Reasonably Achievable." The proposal has drawn significant attention, particularly in the nuclear energy sector.
However, this change would not directly affect the majority of healthcare workers in interventional fluoroscopy.
The NRC regulates radioactive materials, not machine-generated radiation like the x-rays produced by fluoroscopy equipment. The radiation exposure that interventional cardiologists, radiologists, cath lab nurses, and CV techs experience daily falls under state radiation control programs, OSHA, and the FDA. The 5 rem annual whole-body occupational dose limit being referenced in the proposed rule is the same limit that has existed under OSHA since the 1970s. That number isn't changing.
So Why Should Fluoroscopy Professionals Pay Attention?
Because of what may happen next at the state level.
Thirty-nine states operate as NRC Agreement States, meaning they've adopted regulatory frameworks modeled on federal standards. Many of these states — and others — have applied ALARA broadly, including to x-ray exposure, even though the NRC's authority is limited to radioactive materials. ALARA has become embedded in state radiation protection culture in a way that extends well beyond the NRC's formal jurisdiction.
If the federal government eliminates ALARA and signals that fixed dose limits alone are sufficient, states may follow suit and apply that same philosophy to x-ray exposure regulations. In a landscape where ORSIF has documented significant variability in state-by-state fluoroscopy requirements — 56.8% of states don't require certification for non-radiologist physicians operating fluoroscopy — any loosening of protective principles at the state level is cause for concern.
Why ALARA Matters Beyond the Legal Minimum
ALARA is the principle that drives hospitals and institutions to invest in radiation safety training, maintain dosimetry programs, and pursue exposure reduction beyond the legal minimum. The 5 rem limit is the ceiling. ALARA is the reason most monitored workers stay far below it.
What ORSIF Is Watching
We will be closely monitoring how state radiation control programs respond to the NRC's proposed rulemaking, particularly states that have applied ALARA to machine-generated radiation. We will also be tracking the NRC's public comment period, expected to open by April 30, for any signals about how the federal framework shift may influence state-level x-ray regulations.